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1 Fees in extended producer responsibility systems: the packaging waste case Mafalda Mota 1,2*, Ana Pires 2,1, Graça Martinho 1, Rita A. Ribeiro 2 1 Universidade Nova de Lisboa, Faculdade de Ciências e Tecnologia, Departamento de Ciências e Engenharia do Ambiente, Campus de Caparica, Caparica, Portugal 2 UNINOVA, Center of Technology and Systems, Campus FCT UNL, Caparica, Portugal * Corresponding author. Phone number: , Fax number: Abstract Most European countries manage packaging and packaging waste through an extended producer responsibility (EPR) system, being the most known thegreen Dot system. This paper presents a comparative studyabout the fees applied by the European Green Dot systems anddiscusses how this economic instrument could promote eco-designby including environmental aspects in the applied fee. Most countries differentiated fees are applied by weight, material function, destination and dimension. Other variations, found between countries, a are related to packaging waste management system, sitespecific technology, costs, taxes and management targets. The first initiatives concerning environmental impacts and waste prevention are observed in countries like Netherlands, Austria, Norway and Czech Republic. Although someefforts, the differentiated fees applied so far, have not been capable to promote waste prevention and environmental impacts reduction. Concerning packaging waste costs, there are evidences that fees contribute to the packaging waste management, however, without a clarification about the items used in its calculation and the real costs of managing packaging waste, it isnot possible to concludethat the fees applied are enough to pay the collection and recycling. Observing theeuropean Green Dot systems fees, there are a variety of values for the same packaging property, within the same material, and there is little information or clarification about which items are included. This leads tothe system being distrustedby most packaging producers at a European scale. If the fee aimsat having an eco-design impact, its composition and calculation method should be clear and include social and environmental aspects, and be used by all European Green Dot systems. To comply with the EPR definition, fees need to be capable of: to highlight wastes concerning environmental impacts; promote waste prevention; and enable fairness of fees applied, regarding packaging costs. Packaging producers shouldbe aware of the consequences of their choices in the way the fee is calculated. Important instruments need to be included in the fee, namely command and control and other economic and information instruments, to ensure that sustainable packaging waste 1

2 will be developed in the future. This could lead to more dynamic differentiated fee calculation, making the producer aware of the destination that their packaging have in the end-of-life. Keywords: extended producer responsibility, packaging waste, green dot fee, sustainability,eco-design 1. Introduction In spite of the increasing European Union legislation, waste is still an environmental, economic and social challenge to society in general. Unfortunately, landfill is the main destination for waste, although recycling has been increasing, mostly because waste hierarchy is not yet promoted, especially waste prevention. These issues are specifically addressed in the Thematic Strategy on Waste Recycling and Prevention COM(2005)666 (ECC, 2005), by proposing a combination of measures promoting waste prevention, recycling and re-use to obtain an optimum reduction in the accumulated impact over the life cycle of resources. An important step forward would be the full implementation of the existing legislation. Concerning packaging waste, the main EU legislation is the Packaging Waste Directive 94/62/EC (European Parliament and Council, 1994) and its amendments. This Directive aims at protecting the environment by ensuringefficient functioning of the internal market, as well asby proposing measures to promote prevention, reuse, fulfilling recovery and recycling targets, and improve collection and recovery systems. This Directive, although common for all member states, was transposed into national laws in many different ways and its implementation even differs within each member state, where different models of compliance can compete with each other. The main instrument applied by the Member States, to answer the Packaging Waste Directive, isthe extended producer responsibility (EPR). Thomas Lindqvist (Lindqvist, 2000) officially formulated the EPR concept in 1990andtwo years laterhe proposed the following definition: EPR is an environmental protection strategy to reach the objective of decreasing the total environmental impact of a product, by making the product manufacturer responsible for its entire life-cycle,especially for the take-back, recycling and final disposal of the product. Another definition is from the OECD (2001), which defines EPR as an environmental policy approach wherethe producer s responsibility for a product is extended to the post-consumer stage of a product s life cycle. Both EPR definitions shift the responsibility upstream, toward the producer and away from municipalities. The original impetus for this shift was two-fold: to relieve municipalities of some financial burden of waste management, and to provide incentives to producers to reduce resources, use more secondary materials, and undertake product design changes to reduce waste (OECD, 2001). The implementation of EPR systems,require the application of economic, regulatory and informative instruments like fees, subsidies, bans/restrictions, permits, targets, standards, labels and information campaigns. In short, EPR does not constitute a policy instrument by itself (Manomaivibool, 2009).A key aspect of the rationale for developing efficient EPR instruments is that, if welldesigned, they have the potential to stimulate low-waste innovation by producers. Changes in product design and specification can have important implications in the level of waste management costs. The incentives for low-waste innovation, established by an 2

3 EPR program, might encourage innovations and, therefore reduce waste management costs and discourage producingmore waste-increasing products (OECD, 2005). According to Mayers (2007), in an EPR context, packaging producers commonly get together and form national collective compliance s or producer responsibilities organizations (PROs), to ensure compliance with EPR requirements. PROs, whether established by producers or waste companies, are created to organize pick-up of waste from designated public and retailer collection points, subsequent treatment and recycling, and reporting of results to national governments. Thus, packaging producers pay to a PRO, usually a non-profit organization, to manage packaging waste on their behalf, by means of a tax or a fee.in this way, the external costs associated with products throughout their lifecycle (including final disposal) are included in the costs faced by waste generators (e.g. in the market price of the product), hence resulting in incentives to both producers and consumers to change their behavior enabling shifting waste management up to the waste hierarchy (Nahman, 2010). Typically, PRO will levy charges on participating firms to cover the net costs of its operation. Some fees promote the use of materials easier to recover otherspromote reducing the amount of a specific material used in a product. Thenet costs usually include the costs of colleting waste products and the costs of subsequent treatment. When the waste packaging is recycled there may be significant costs of separation, sorting and transportation. In some cases, when commercially-profitable recycling operations exist, the PRO may receive income from the sale of recyclable materials to recycling companies. In other cases, recycling ismandatory but may not be commercially-viable. In these cases, the PRO will need to pay to have the recycling undertaken. The PRO will have a trading loss if its operating costs exceed any income received from recyclers; and this will need to be covered by contributions (fees) from members. Such contributions may be related to the current and/or past sales volumes of participating firms, and could also be differentiated to reflect characteristics of the products of individual firms, especially those affecting waste management costs (OECD, 2001). PRO Europe (2012a, 2012b, 2012c) believes that the application of EPR in management of packaging and packaging waste provides: a) incentives for companies to optimize packaging and reduce environmental impact through eco-design and design for recycling; b) contributes to decoupling packaging production and packaging waste disposal from economic growth; c) encourages cost and resource efficient management of packaging waste; and d) ensures efficient use of the financial contribution made by industry. The application of packaging waste directivesand EPR in European countries has resulted in improvements onpackaging waste collection, treatment and recycling rates. However, they suffer drawbacksin complying with a sustainable packaging waste management. For example, concerning end-of-life waste management, the payment to local authorities for the collection and sending to recycling is usually not fully supported by producers, as mentioned by da Cruz et al. (2012) for the Portuguese Green Dot system; Melanen et al. (2002) pointed that one of the major problem of EPR systems, for packages and packaging waste, has been its lack of coordination with municipal waste management systems. 3

4 In general, EPR are not effective for design improvements and technological changes, innovation and eco-design of packaging. Røine and Lee (2006), have shown there is a correlation between Norwegian EPR policy and technological change and innovation, but the causality is rather weak.in fact, packaging waste generation has not yet decoupled from the economic growth (mentioned by the European Environment Agency in 2008), sincetheeuropean Union old Member States (EU15) only saw a slight decoupling from gross domestic product between 1998 and Until now, the fees applied are basically transferred, through the supply chain, until the last consumer the real stakeholders who pay it thus distorting the principle of the fee. This situationis even aggravated when considering that the fee is not discriminated in the receipts, and thus there is no available information to help change the packaging consumption and promotion of eco-design. Therefore, it is crucialto find the reason why EPR do not promote environmental impacts minimization from packaging life-cycle, and how it is defined to support packaging waste management costs. Hencethe aim of this work is to contribute to find answers to these questions by performing a survey of EPR fees applied by Green Dot System in member countries of PRO Europe. Data from 33 European countries was collected and analyzedincluding EU-27 minus Denmark, plusadding Croatia, Iceland, Macedonia, Norway, Serbia, Turkey and Ukraine. 2. Green Dot system: the packaging EPR system The first EPR program began in 1991 in Germany, with the German Packaging Ordinance. Under this ordinance, producers of all kinds of packaged products are required to either individually take back their packaging or join the Duales Systems Deutschland (DSD), an industry packaging waste management organization (Hanish, 2000). Paying a fee, DSD licenses its green dot label to producers, who are then allowed to print it on their packaging. This label informs consumers that the management of packaging waste has been assured. According to OECD (1998), initially the license fees were based on volume of packaging material regardless of its type and density. The Green Dot fees were intended to cover collection and sorting of packaging material only, with an exception for plastics, where recycling costs were covered, because the industry would not make the necessary investments in recycling capacity. Nevertheless, the volume-based fee structure failed to account for differences in weights of material processed per volume unit,as well as for the widely differing costs of sorting and recycling individual packaging materials. In October 1993, a new fee structure was introduced, this one based on weight and packaging material type, which reflects the relatively higher costs for plastic (and composite) materials (OECD, 1998). Immediately after, several other countries implemented the German concept:, the Netherlands, France, Austria, and Belgium. To ensure communication and co-operation among PROs in different countries, and to address hindrance to free trade through introduction of symbols, the PRO Europe was then founded with headquarters in Brussels (OECD, 1998). PRO Europe is an initiative of the DSD, seeking to promote the use of the Green Dot symbol within Europe by other PROs (OECD, 1998). 4

5 Green Dot is a registered trademark of PRO Europe and is protected in 170 countries. It indicates that a company has transferred its obligation for the collection and recovery of material to a packaging compliance (EEA, 2005). The Green Dot logo indicates that the manufacturer of a packaging has purchased a license for the right to use the Green Dot trademark and is obligated to abide by the regulations that license imposes, with fees funding the recovery and recycling system (Jedlicka, 2010). s for packaging have been identified in 24 Member State (Table 1) (the United Kingdom uses a system of tradable credits for packaging - no link between industry and collection at local level). Denmark, Hungary and Netherlands use taxation systems and deposit-refund systems and Switzerland has special systems for each material. These s essentially oblige packaging producers to financially support (to varying degrees) the implementation of recycling s for packaging waste (Watkins et al., 2012). Notice that the Netherlands, Italy and Ukraineare members of PRO Europe but do not participate in the Green Dot program. Among the EU countries, Italy, the Netherlands, Denmark, UK and Finland are not using the Green Dot symbol. The Italian packaging recovery, CONAI and the Dutch packaging recovery use no symbol at all. In Denmark and Hungary, a packaging tax is applied and Finland uses the symbol PYR. In the UK, as well as in the NAFTA area, the symbol does not demonstrate a financial contribution to the recovery of packaging but it is used under license by companies placing packed products on the UK and the NAFTA market, as well as in other (often English speaking) European markets, such as Ireland. It is generally recognized that, although the symbol bears not the usual meaning in the UK and in NAFTA, it is often more environmentally friendly to use the same packaging design in multiple destinations (PRO Europe, 2013). 5

6 Table1. System characteristics Country Green Dot Compliance Packaging Waste Directive Compliance Licensees required to print Green Dot logo on packaging Type of packaging recycled Main type of Who finances the collection, sorting and recovery of the packaging waste Austria AT Yes Yes No. Using the Green Dot is optional in Austria, but it is recommended for packaging that will be used by households Belgian BE Yes Yes No Household Bulgaria BG Yes Yes No Cyprus CY Yes Yes Yes (some deposit-refund s) (some deposit-refund s) Licensees pay a material-specific licence fee (in accordance with the valid tariffs) for the waste quantities reported Pays the full cost of collection and sorting and receives the proceeds from the sale of recycled materials. The net cost is financed by its member companies The activities are financed by the licence fees of the members The financing of collection, sorting and recovery of the household packaging waste is provided by the system (80% of the cost) and by participating local authorities (20% of the cost) Czech Republic CZ Yes Yes No. There is no obligation to print the Green Dot on their packaging Household and commercial Is financed by the licence fees paid by member companies 6

7 Country Green Dot Compliance Packaging Waste Directive Compliance Licensees required to print Green Dot logo on packaging Type of packaging recycled Main type of Who finances the collection, sorting and recovery of the packaging waste Dinamarca DK No There is no national program and the responsibility for collection of household and commercial packaging recovery falls upon the municipalities. NA NA Tax and depositrefund s Estonia EE Yes Yes No Finland FI Yes Yes France FR Yes Yes Germany DE Yes Yes No Greece GR Yes Yes No, the Green Dot symbol is not used in Finland. Yes, the printing of the GD symbol is mandatory by contract. Yes. However, exceptions can be made upon mutual agreement. Household and retail Industrial and commercial packaging from industry and trade, drinks packaging with a deposit from consumers with vending machines, other consumer packaging in bring systems Household Household and some commercial /depositrefund s /depositrefund s /depositrefund s The system is based on a full cost structure Packers and fillers The system is based on a sharedcost structure Collection, sorting and recovery of the packaging waste are fully financed from the participation fees paid for use of the system by the obligated parties from the and retailing sectors Fillers, packers and importers of packaging material 7

8 Country Green Dot Compliance Packaging Waste Directive Compliance Licensees required to print Green Dot logo on packaging Type of packaging recycled Main type of Who finances the collection, sorting and recovery of the packaging waste Hungary HU Yes Yes Ireland IE Yes Yes No. The use of the mark is not a legal obligation. No. this is not a legal requirement in Ireland. However, approx. 90% of Repak members do apply the Green Dot symbol to their primary packaging. Italy IT No Yes NA All Latvia LV Yes Yes No Lithuania LT Yes Yes No Household and Tax Shared-cost model Companies are obliged to pay an Environmental Contribution, depending on the type of packaging material and on its weight Fillers, packers and importers Full cost system Luxembourg LU Yes Yes No Household and commercial Fillers, packers and importers Malta MT Yes Yes No Tax (some deposit-refund s) The system is financed by members fees Netherlands NL No Yes NA Poland PL Yes Yes No Portugal PT Yes Yes Yes, on primary packaging. SPV s licensees are legally obliged to print the Green Household and commercial Producers/importers bringing the packaging first on the market Fillers, packers and importers Fillers, packers and importers 8

9 Country Green Dot Compliance Packaging Waste Directive Compliance Licensees required to print Green Dot logo on packaging Type of packaging recycled Main type of Who finances the collection, sorting and recovery of the packaging waste Romania RO Yes Yes No Dot symbol on their primary household packaging but printing on all other packaging types is not required either by law or by contract with SPV. Commercial and household Shared-cost model Sweden SE Yes Yes No Slovakia SK Yes Yes No All Slovenia SI Yes Yes No Spain ES Yes Yes No. Spanish law stipulates a marking obligation (packaging identification) and therefore all packaging licensed in the Integrated Management System must carry the Green Dot symbol. some commercial /depositrefund s The municipality finances the separation of waste on the basis of a contract with the waste management companies ENVI- PAK pays an additional contribution based on the amount of packaging waste selected and forwarded for recycling and/or recovery The licensees finance the collection, sorting and recovery of packaging waste. All licensees pay the same licence fee, which is different according to the packaging material Fillers, packers and importers 9

10 Country Green Dot Compliance Packaging Waste Directive Compliance Licensees required to print Green Dot logo on packaging Type of packaging recycled Main type of Who finances the collection, sorting and recovery of the packaging waste United Kingdom UK Yes Yes No. The symbol has no meaning in the UK and so is not compulsory but can be used under licence. (tradable credits) Switzerland No Yes* NA Norway Yes Yes No, but members are both entitled and encouraged to do so. The members finance the additional costs associated with ensuring that packaging is moved from energy recovery and deposit to material recovery. This includes buying source separated consumer packaging from municipalities, ensuring that companies can dispose of source-separated packaging for free and guaranteeing functioning markets for recovery References Adapted from PRO Europe (2011, 2012a, 2012b, 2012c) 10

11 3. Material and methods To perform the survey a considerable review of the fees applied in Green Dot systems at European countries has been conducted. Most data was obtained from PRO-Europe website and reports for The data was analyzed and grouped in such way that could highlight whichfactors are included in the fees definition, including the regular factors weight and material type, already pointed out by Lifset and Lindhqvist (2008). It should be noted that the survey encompasses somelimitations concerning studies in native languages other than English, as well in available English data collection. 4. Results from survey analysis From the analysis conducted of all producer fees applied in EPR Green Dot system, all over Europe, it was possible to observe the major factors which justify differentiated fees: geography, packaging material, packaging function, packaging destination and packaging dimensions. Fees are all defined, firstly in weight, than the other factors are combined, resulting in different fees. Each one of these factors will be analyzed in next sections Geography Geography refers tosite-specific aspects from each country, since national policies for packaging and packaging waste arediverse. Looking at Figure 1 it is visible the countries where the fees are higher: Austria, Czech Republic, Estonia, Malta, Netherlands, Spain, and Sweden. In opposition, countries where fees are lower are: Finland, France, Germany, Macedonia, Poland, Romania, Serbia, Turkey, and UK. There are several justifications for differentiated fees applied in European countries, which can be divided in several items: Collection and recycling system in terms of technology and packaging considered Collection and recycling costs covered (appointed by Watkins et al., 2012) Other taxes involved (like landfill and incineration tax) Other targets besides EU legislation. 11

13 Concerning collection and recycling system, countries differ a lot in terms of collection system: in terms of separate collection it can be done through bring systems and door-to-door systems ; it can be collected in several fractions, e.g. in Portugal the number of fractions is three (glass, plastic/metals/composites and paper/cardboard), when in Austria packaging can be collected in in more fractions (paper, colored glass, clear glass, plastic/metal, only plastic or only metal, and beverage cartons (ARA, 2013)); the packaging source considered, i.e. only household or non-household collection costs are included, like happens in Austria in Czech Republic where commercial packaging collection is included (Kjær et al., 2012); existing material recovery facilities technology (manual, semi-manual or automated); recycling technology (in Portugal there is no specific technology for polystyrene recycling, the one existing is the production of plastic-wood like outdoor furniture, a downcycling technology); and recovery/recycling efficiency due to technology and to material arriving to the processes (quantity and quality). All the different possibilities are reflected in different costs for each country. Also, countries thatare now starting their systems will possibly reduce the fee during the next years, when the collection, sorting and recycling structure is more efficient. is intended to cover costs from packaging waste management. Besides producer fee, the system is also supported by revenues from packaging material sales. Although the equation is simple, there are evidences from Watkins et al. (2012) that only in Austria and Belgium (also Denmark but is out of our range) theproducer fee covers all costs oflocal authorities/waste collection authorities, being unclear ifthere arefull cost coverage in other countries. For example, Belgium EPR system only cover sales packaging, when Austrian and Italian covers all packaging (Kjær et al., 2012). Other taxes can also be involved in producer fee calculation, namely landfill and incineration taxes. It is speculated that packaging waste, which is not collected separately andis going to landfill or incineration will pay those taxes, being included into the producer fee. Austria, Sweden and Czech Republic are some countries where such tax exists. Concerning established targets and how demanding arethe targets for collection and/or for recycling, more efforts (investment in technology and resources) must be made to reach them. For example Austria has a 75% recycling target for paper/cardboard from household system and 85% for commercial system (Scharff, 2011), when European legislation has established 60%; Sweden has, for 2011, a recycling target of 70% for metals (when European legislation has established 50%); most targets applied in Netherlands are higher than the defined by EU legislation Packaging material In general, all countries have different producer fees for each main material (plastic, glass, metals, wood). Such differencesarepossibly related to the costs and revenues that each material presents. For example, glass and wood present lower producer fees because they are denser, making collection more effective in the case of glass; in the case of wood, the collection is almost inexistent, being the 13

14 transportation made by the owner into the recycling center. Also the recycling market influences such economic balance, resulting in different producer fees. The Netherlands fees are based in environmental impacts from the life cycle assessment. Hence the fees applied to plastic, aluminum, and ina lesser extent to other metals, are higher than the one applied to glass, since those materialshave the highest environmental burden and are more costly to manage. The aim is to promote packaging made of glass and paper/cardboard. Besides variations at the main waste fractions, inside of each waste fraction there are producer fees differentiated by material. Such is possible to observe for waste fractions paper and cardboard, plastic and metals. In Table 2 it is possible to observe which the targets are: beneficiate materials recyclability (concerning plastic and paper/cardboard). Aluminum presents a higher producer fee than steel due to the amounts available in packaging waste to be recovered, making steel collection, sorting and recovery more efficient than aluminum. These differentiated fees can be considered as promoting eco-design. Other specific cases of eco-design promotionare: France rewards clear PET packaging compared to colored PET with a lower fee; Netherlands applies a reduced fee to bioplastics compared to generic plastic packaging; Belgium and Luxembourg have lower fees for PET and HDPE than for generic plastic packaging. Table 2. Average producer fees by material Materials Average producer fee ( /t) Countries where is applied Paper Austria, Slovenia, Czech Republic, Portugal, Malta, Finland Cardboard Finland, Norway Corrugated cardboard Norway, Czech Republic, Finland Generic paper/cardboard PET Belgium, Croatia, Cyprus, France, Lithuania, Luxembourg, Romania, Slovenia, Spain HDPE Belgium, Cyprus, Lithuania, Luxembourg, Spain EPS Austria, Norway Bio-plastics Austria, Netherlands Generic plastic Steel or ferrous All except Bulgaria, Cyprus, Estonia Germany, Greece, Hungary, Iceland, Latvia, Lithuania, Macedonia, Netherlands, Norway, Serbia, Slovakia, Slovenia, Turkey Aluminum All except Estonia, France, Latvia, Lithuania, Macedonia, Norway, Serbia, Slovakia, Slovenia, Turkey, Iceland Tinplate France, Finland, Germany, Ukraine Generic metals References: Adapted from PRO Europe (2012a, 2012b, 2012c) 14

15 4.3. Packaging function Packaging function is related to the packaging use. In this article the definition presented in Directive 94/62/EC (European Parliament and Council, 1994) is the one followed, being divided in three types: sales packaging or primary packaging: packaging conceived so as to constitute a sales unit to the final user or consumer at the point of purchase; grouped packaging or secondary packaging: packaging conceived so as to constitute at the point of purchase a grouping of a certain number of sales units whether the latter is sold as such to the final user or consumer or whether it serves only as a means to replenish the shelves at the point of sale; it can be removed from the product without affecting its characteristics; transport packaging or tertiary packaging: packaging conceived so as to facilitate handling and transport of a number of sales units or grouped packaging in order to prevent physical handling and transport damage. Transport packaging does not include road, rail, ship and air containers. In Table 3 it can be observed that, generally, primary packaging presents a higher producer fee. Thiscan be justified by the higher costs in managing such packaging, since secondary and tertiary packaging areusuallymanaged by the owners (which is the distributer (cash and carry) sector) and not by the municipalities (e.g. Portugal). This differentiated factor probably only reflects producers requirements to pay a fee more adequate to their packaging, especially when their packaging will neither end at municipalities collection, nor having to support it. Table 3. Average producer fees by function Materials Packaging ( /t) Countries where is applied Paper Primary Czech Republic, Estonia, Malta, Portugal, /cardboard Secondary Slovenia Tertiary Plastic Primary Austria (only tertiary), Czech Republic, Secondary Estonia, Hungary, Malta, Portugal, Tertiary Slovenia Metals Primary Czech Republic, Estonia, Malta, Portugal Secondary Tertiary Wood Primary Czech Republic, Malta, Portugal Secondary Tertiary References: Adapted from PRO Europe (2012a, 2012b, 2012c) 4.4. Packaging destination Packaging destination is related to the stage when packaging becomes waste and it can result from households or in (no household) producers. Further, service packaging, as carrier bags, although they become waste inhouseholders, there isthe need to highlight it separately. In Table 4 it is presented producer fees practiced in some European countries. Comparing them, the 15

16 household packaging presents the higher cost, which can also be explained by the collection, sorting and recycling costs related to each packaging type, similar to the case in section 4.3. Service packaging also follows the same tendency, since it is also managed by household collection s. Table 4. Average producer fees by destination Materials Packaging ( /t) Countries where is applied Paper Household Cyprus, Czech Republic, Luxembourg, /cardboard No household Portugal, Sweden Service Plastic Household Austria, Croatia (only service), Cyprus, Czech No household Republic, Finland, Norway (only service), Service Portugal, Sweden Metals Household Czech Republic, Portugal, Sweden No household Service Wood Household Cyprus, Czech Republic, Luxembourg, No household Portugal Glass Household Luxembourg, Portugal No household References: Adapted from PRO Europe (2012a, 2012b, 2012c) 4.5. Packaging dimensions Besides the packaging material addressedin section 4.2., taxing packaging dimension can alsopromote eco-design. Only three European countries consider volume-dependent fees, as shown in Table 5. Spain also has a volume/weight/unit fee specific for glass and Croatia has defined volume/unit and material fee for drink packaging, which can be consulted in PRO Europe (2012). Fees depictedin Table 5 are implemented together with weight-based fees, which reflect waste prevention principles, and these are also in accordance with eco-design principles. Table 5. Average producer fees by dimensions Materials Packaging ( /t) Countries where is applied Plastic Small Austria, Czech Republic, Norway Large Metals Small Austria, Czech Republic, Norway Medium Large Glass Small Norway Medium Large References: Adapted from PRO Europe (2012a, 2012b, 2012c) 5. EPR fees and theireffect in packaging and packaging waste management The results presented so far, provide an overviewon the fees implemented in the European countries by the respective Green Dot systems. The material with more differentiated fees is plastic, being the less 16

17 differentiated glass. This can be explained by the fact that plastic has several functions, while glass is mainly (not to mention only) used as primary packaging. Austria and the Czech Republic are the countries with more differentiated fees, concerning all the factors identified besides weight: material, function, destination, and dimensions. It is also observed a fairness concern in countries where the fee is defined by function and destination, whichreflects the costs that specific packaging will have during its end-of-life stage. However, it will only be fair with supervision to ensure that packaging or secondary and tertiary packaging waste does not reach the primary and household packaging waste management system, or else the fee will not be enough to support it. The disparity between the fees of different countries can also be explained by the question of who finances the collection, sorting and recovery of the packaging waste. For example, in Portugal and Sweden, fillers and importers, in a clear adoption of the shared responsibility principle, finance the system. In Cyprus the financing of collection, sorting and recovery of the household packaging waste is provided by the system (80% of the cost) and by participating local authorities (20% of the cost). The system fully finances the recovery of commercial/ packaging. The system in France and Serbia is based on a shared-cost structure and most of the costs are covered by the financial contributions paid to Eco-Emballages by fillers, distributors and importers of household products. The remainder systems are mainly financed by the tax paid by citizens to the local authorities. The expected effects of EPR should focuson two main aspects: in the way how packaging waste has been managed, in terms of collection and recycling;and in terms of its environmental impacts during life cycle, being reflected in aspects related withdesign for environment and design for recycling. An increasing of waste collected and send for recycling has been observed in most EU countries. In fact EEA (2013) highlights this fact, mentioning that a recycling rate of 63.2% was achieved at EU-27 level in It is notorious that Green Dot systems provide a significant contribution to the financial support of packaging waste management, namely financing collection and sorting systems; as well as in complying with EU legislation. However, to ensure thatcosts are totally covered by the fee (and other revenues) will be difficult to prove. For example, in Portugal it is claimed that producer feesarenot enough to pay collection costs (da Cruz et al., 2012); mainly because the cost quantification by local authorities (or municipalities) is deficientdue to the unstructured financial management inside the municipality. Further, the formula to calculate the fee is not publicly available, hence it is difficult to assessif it is the same in all countries (in this work it was assumed that fee supports packaging waste collection, but its composing items are unknown). Without an appropriate inventory,forall countries, about all items considered in the costs,how they are calculated, as well other revenues besides the fee, a truly European eco-fee will be difficult to accomplish.for example, in countries where incineration and landfill tax is applied, it was not possible to know if it is effectively included in the fee and, if so, how it is done. Concerning the environmental component of EPR, it is not visible that fees applied have improved significantly packaging waste management in European countries withgreen Dot systems. Mazzanti and Zoboli (2005) and EEA (2013) pointed that decoupling packaging waste from economic growth, on the EU policy objective of waste prevention, has not been accomplish yet. In Figure 2 it is possible 17

18 to observe, for EU-15, the evolution of fees applied in average by material as well as by packaging waste generation.during the period the glass packaging has been reduced, even so being the material where the fee is lower, and from an environmental point of view the better option. Paper/cardboard are also adequate materials from an environmental point of view, having raised their packaging waste. Plastic is the case where a significant fee reduction was observed, and anincreasein the packaging waste was observed. Although other policies, such as packaging production costs and technical requirements can be involved, the fees applied so far have not been able to promote waste prevention changes amount of waste and adverse impacts from materials used following the aimof EU legislation.in fact, waste prevention measures,fromthe Waste Framework Directive 2008/98/EC (European Parliament and Council, 2008),together with othermandatory waste prevention programs, could be articulated with fees to promote waste prevention.fees should be able to include waste prevention programs, which could lead to environmental-friendly packaging. Packaging waste generated (1,000 tonnes) 30,000 25,000 20,000 15,000 10,000 5,000 0 Plastic Glass Paper/cardboard Metals Wood Packaging waste generated 2004 Packaging waste generated 2010 Fee ( /t) 2004 Fee ( /t) 2012 Fee ( /tonnes) Figure 2. Evolution of fees and packaging waste generation, in EU-15 (Eurostat data (Eurostat, 2013), Der GrünePunkt, 2005) Waste prevention and eco-design (or design for environment or design for recycling) are concerns not exclusive of EU legislation, but also of theinternational community. The Technical Committee ISO/TC 122, Packaging, Subcommittee SC4, Packaging and Environment, elaborated the ISO (ISO, 2013) family of norms, with three main aims: a) reduce the packaging environmental impact; b) ensure that it can be reused or recovered after use; c) provide the function for users and producers. One of the main targetsis the minimization of substances or mixtures hazardous released to the environment in packaging. Fees from Green Dot systems should be capable of incorporating this target(and others present in the family of norms) to penalize producers using environmental detrimental materials and 18

19 benefit producers who are making efforts to make the packaging more sustainable (including an economic perspective). A good case of inclusion of environmental impacts is The Netherlands and, outside Green Dot system, the Danish packaging tax. For example, the cost of recycling plastic packaging can be significantly lower if: contaminants that cannot be readily separated from the packaging are avoided; if particular types of plastics are avoided; and if particular production methods are used (Calcott and Walls, 2005). Small efforts in promoting waste prevention, design for environmental or design for recycling, have been found in Green Dot systems, such as the case of volume/weight or weight/material. A recent initiative toward this aim has been found in the French Green Dot System. According to Eco- Emballages (2012), the fee will be calculated including a bonus/penalty item. The bonuses and penalties depend on the eco-design and the contribution of the weight and unit. They have also an incentive for the companies to use messages encouraging the consumer s participation and to use packaging that facilitates the recycling process. Packaging producers that implement the actions of ecodesign (reduced weight, volume or switching to refills) or that will bring sorting awareness messages will receive a bonus of 2%. Conversely, a penalty of 50% (against 20% in 2011) will apply for packaging that disrupts the sorting and recycling. The initiative from Eco-Emballages will need a validation to prove that a specific change in the packaging isdue to these new items. This will also be needed for other differentiated fees to enable analysis of the fee effectiveness. In addition, to apply a bonus/penalty to producers also has an educational advantage since this cost cannot be transferred to the end consumer in the short term (it is applied in the year that it has entered in force). 6. Conclusion The comparative study presented in this work clearly demonstrated that fees applied by most European Green Dot systems are very different for the same packaging property in the same material. Such differences can be explained by the elements used to calculate the feeand also by the waste management costs of the components included (collection, sorting, recycling).unfortunately,since the fee calculation and how its composingitems are defined isnot clear, hence it difficult to perform acomparison of the applied fees at European level. The lack of common rules to define fees can lead to competition problems of importation and exportation of packaged goods, because prices will be higher in countries with higher fees, and, furthermore, there is no joint European effort to promote eco-design and create sustainable systems. Further,packaging producers at a European scaledo not trust the Green Dot system, because it is difficult to justify the different fee values each country uses. If the fee intends to have an eco-design impact, it should be clear which items are to be considered in its calculation and the justification of the respective fee values, and be applied by Green Dot systems. If a single country is imposing fees to promote a particular feature and other countries do not do the same, there will be no advantage to change the feature to comply with only one country. The effects of differentiated fees in packaging and packaging waste neither followthe theoretical definition, since no reduction of packaging waste generation has been observed, nor even promotesusage of packaging materials, more environmental-friendly. However, it can be observed 19

20 some positive effects in packaging waste, since plastic packaging has increased during the period while plastic fee has been reduced. Environmental impacts differentiation, as well eco-design differentiation, are not enough to change environmental impacts, there is a need for more articulation with command and control, economic and information instruments. In the future, and to make EPR feasible and viable in the context of European Waste Framework Directive, EPR must be capable to promote packaging waste hierarchy management and be associated witha life cycle perspective. Sustainability of packaging and packaging waste are also aspects to consider when implementing an EPR, which should lead to an obvious clarification on the fee calculation, and such fee should be capable ofincorporatingboth environmental and social aspectsto clearly promote packaging eco-design at the European level. Differentiated fees should be fair to packaging producers and consumers, to allow economic feasibility, and to reduce environmental impacts. Producer should paid for the management cost related to its packaging, being based on the packaging flow during its end-of-life stage. A material flow analysis could be a possible way to afford it, being possible to include other instruments like incineration tax and landfill tax. This option could led to a more dynamic differentiated fee calculation, making the producer aware of the destination that their packaging have in the end-of-life. For example, if a producer is awarethat hispackaging is not going to be recyclable, more information should be provided to consumer/disposable stakeholder. Time and resources would be needed, as well the involvement of all stakeholders not just at a national but also at a European level. Differentiated fees have potential to contribute to a more sustainable packaging conception and design, but a bigger effort in supervision and common policy is needed to ensure that improvements have been made to the packaging. Acknowledgment The authors greatly acknowledge the financial support given to the PoVeRE project by Sociedade Ponto Verde, which supports this work. References ARA. Performance report 2012; 2013, Available at REPORT/ARA_Leistungsreport2012_ENGLISH.pdf [accessed Calcott P, Walls M. Waste, recycling, and Design for Environment :Roles for markets and policy instruments. Resource and Energy Economics 2005; 27: da Cruz NF, Simões P, Marques RC. Economic cost recovery in the recycling of packaging waste: the case of Portugal. JournalofCleanerProduction 2012; 37:

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